​NRECA, the American Public Power Association (APPA), the Coalition of MISO Transmission Customers, the National Association of State Utility Consumer Advocates (NASUCA), the Organization of MISO States, Inc., the PJM Industrial Customer Coalition, and the Transmission Access Policy Study Group submitted a white paper to the Federal Energy Regulatory Commission (FERC) urging it not to make changes to the two-step discounted cash flow (DCF) method used to set the return on equity (ROE) component of electric transmission rates. The white paper was developed in response to an Edison Electric Institute (EEI) proposal to change the existing approach to calculating ROE. FULL WHITE PAPER